General Information The Adviser, a Texas limited liability company, was formed in February 2020.
Advisory Services The Adviser provides discretionary and non-discretionary portfolio management as well as financial planning services to individuals, including high net worth individuals, corporations, foundations, retirement and pension plan participants, and other entities. At the outset of each client relationship, the Adviser spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, tolerance for risk, and broadly identifying major goals of the client. Based on its reviews, the Adviser generally develops with each client:  a financial outline for the client based on the client’s financial circumstances, present needs, near-term and long-term goals, and the client’s tolerance for risk (the “Financial Profile”); and  the client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments the Adviser will make or recommend on behalf of the client based on the Adviser’s own research and analysis in order to meet those goals. The Investment Plan generally includes investment management strategies designed to achieve the client’s near-term and long-term goals while carefully managing the influence of risk on their success. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client, but are not necessarily written documents.
PortfolioManagement As described above, the Adviser will develop an Investment Plan with each portfolio management client. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by the Adviser based on updates to the client’s financial or other circumstances.
To implement the client’s Investment Plan, the Adviser will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, the Adviser will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on the Adviser in the

management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of the Adviser.
FinancialPlanning The Adviser generally provides financial planning services to those clients in need of such services in conjunction with portfolio management services. The Adviser’s financial planning services normally address areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of these services is to assess the financial circumstances of the client in order to more effectively develop the client’s Investment Plan. Financial planning services are not offered as stand-alone services or for separate fees but are typically provided to clients in conjunction with the management of the portfolio.
Sub-Advisers When appropriate and in accordance with the Investment Plan for a client, the Adviser may utilize one or more sub-advisers (each, a “Manager”). Having access to various Managers offers a wide variety of manager styles, and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. The Adviser will select the Manager(s) it deems most appropriate for the client. Factors that the Adviser considers in selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment advisory services for the portfolio. Under most circumstances, the Adviser retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent.
In any case, with respect to assets managed by a Manager, the Adviser’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio.
Principal Owners Mr. Michael Bailey is the principal owner of the Adviser.
Type and Value of Assets Currently Managed As of December 31, 2023, the Adviser managed approximately $287,596,844 on a discretionary basis and $22,863,742 on a non-discretionary basis.